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Metinvest Trametal SpA
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Code of Ethics and Organisational, Management and Control Model

Metinvest Trametal S.p.A., aiming at making known all principles and values on which it bases its business conduct, has adopted the Code of Ethics of Metinvest Group and has, in parallel, approved an Organisational, Management and Control Model, pursuant to the Italian Legislative Decree 231/2001 concerning the administrative liability of entities.

The Code of Ethics, whose widest diffusion is promoted by Metinvest Trametal, contains rules of behavior, moral conduct and ethical principles on which Metinvest Group daily bases its image and its reliability on the market.

A full compliance with these values is requested to all those who work with Metinvest Trametal in order to achieve its goals: in first place, employees and members of the management and supervisory bodies, but also are encouraged to comply with these values all those ones that, being outside the corporate structure, have any kind of working relationships with Metinvest Trametal, such as consultants, agents, sales representatives, contractors, suppliers.

In the same perspective of consolidation of a corporate culture based on principles of fairness, transparency and legality, there was also the adoption, during 2015, of the Organisational, Management and Control Model, pursuant to the above mentioned Legislative Decree 231/2001, thanks to which Metinvest Trametal, following a thorough analysis aimed at identifying the potential activities at risk of commission of corporate offences, is committed to establish a system of rules and organizational controls, permitting the identification and the prevention of commission of said offenses.

With the specific task of monitoring the functioning, effectiveness and compliance with the Model and its updating, within the Company a Supervisory Board (Organismo di Vigilanza) has been instituted.

Therefore, the Organisational, Management and Control Model, as well as the Code of Ethics, which is an integral part of it, takes place in the more comprehensive project of diffusion of those principles and values that Metinvest Trametal aspires to, and for that reason it is in the Metinvest Trametal’s interest to enter into business relationships with subjects that share the same principles.